Client Alert: U.S. EPA’s May 12, 2016 Actions Affecting the Oil and Gas Industry

On May 12, 2016, the U.S. Environmental Protection Agency (“EPA”) announced a number of new regulations and an information collection initiative that will affect the oil and gas industry.  The regulations include the promulgation of amendments to New Source Performance Standards (“NSPS”) Subpart OOOO and new Subpart OOOOa.  With these regulations, EPA aims to curb emissions of greenhouse gases (“GHGs”) (specifically methane), volatile organic compounds (“VOCs”), and toxic air pollutants from new, reconstructed, and modified oil and gas sources.  Additional rulemakings include the Source Determination Rule applicable to air permitting in the oil and gas industry and a final federal implementation plan (“FIP”) applicable to minor new source review in Indian Country.  The Agency also announced its intention to issue an information collection request (“ICR”) to require companies to provide information as a prelude to promulgating comprehensive regulations to reduce emissions from existing oil and gas sources and requested public comment on the ICR.